FAQs: Uniform Closing Dataset

5. How does the UCD relate to loan delivery requirements?

The UCD in the XML file format with the CD PDF embedded must be successfully submitted prior to loan delivery. Every loan purchased by the GSEs requires a UCD submission.

Loans submitted to a GSE’s Selling/Loan Delivery solutions without a corresponding UCD XML file containing an embedded CD PDF will receive a critical/fatal edit and are not eligible for purchase.

6. Can my UCD XML files include any “extra” data that is not included in Appendix I: UCD Delivery Specification?

The GSEs strongly advise against delivering non-UCD data in the UCD XML files. The UCD XML files delivered to the GSEs should contain only the data specified in Appendix I: UCD Delivery Specification.

If non-UCD data is submitted, it must be well-formed XML or the file will fail. All data elements in the file must pass MISMO v3.3.0299 validation. Data not in the UCD Delivery Specification will not be processed by either GSE’s UCD collection solution.

7. What is the relationship between data on the UCD and the information on the CD?

Data provided in the UCD XML file must support disclosures on the CD PDF. The GSEs expect data delivered in the UCD XML file to reflect the data on the CD. The GSEs also require certain additional data points as stated in the UCD Delivery Specification.

8. Do the GSEs provide testing environments for their CD collection solutions?

Yes, each GSE has established a testing environment that can be accessed by lenders and vendors. Additional details can be found on the GSEs’ respective UCD web pages on FannieMae.com and FreddieMac.com.

9. What are the GSE Requirements for the CD embedded in the UCD File?

• Timing/Version: The CD PDF should represent the most accurate agreed-upon terms of the loan at time of loan delivery to the GSEs. If, after closing but before delivery of loans to the GSEs, information on the CD was updated and a revised CD was provided to the borrower, the updated UCD data and updated CD must be provided in the XML.
• CD Copy: The PDF does not need to be a first-generation file; however, the CD must be clear and legible.
• Multiple Borrowers: For transactions with multiple borrowers where the lender has issued a separate CD to each borrower, the lender should embed only one representative copy of the CD in the XML file.
• Simultaneous Seconds: For transactions with loans having a simultaneous second (e.g., an 80/10/10 transaction), the lender should embed only the copy of CD for the loan being purchased.
• Construction Loans (for Fannie Mae Construction-to-Permanent and Freddie Mac Construction Conversion): The GSEs only purchase construction loans at the permanent financing phase of the transaction. Every loan purchased by the GSEs requires a UCD submission. For a single-close loan (without an executed modification) or a two-close loan, the latest CD that discloses the terms of the permanent financing must be included in the UCD file submission. Single-closing construction-to-permanent and construction conversion loans must meet QM requirements and may require an update to the UCD submission if a modification impacts QM data points (i.e., Annual Percentage Rate (APR), Average Prime Offer Rate, Note Amount, etc.) If a modification has been completed an updated CD may not be required by regulation, but a CD is required in the submission. The original CD may satisfy the requirement.
• CD Revised Prior to Delivery: If the loan has closed, but has not been delivered to a GSE, and a revised CD was provided to the borrower, the most recent version of the CD must be included in the updated UCD XML file submission.
• Split Disclosures: When Split Disclosures are used, the Seller Disclosure CD does not need to be included in the UCD file.
• Signatures: The CD included in the XML does not to be signed; however, the loan seller may wish to continue current industry best practices of obtaining interested party signatures in accordance with CFPB’s TILA-RESPA Integrated Disclosure (TRID) Rule signature requirements.
• Addenda: Addenda associated with the CD do not need to be included.

10. What is the purpose of the Alternate Form?

The CFPB created the Alternate Form format specifically to capture disclosures for refinance transactions. The form is abbreviated to omit disclosure of information not applicable to refinances (that is, fields related to a property seller). If the Alternate Form is provided to the borrower, its CD PDF must be embedded in the XML file.

11. Do the GSEs require use of the Alternate Form for Refinances?

The GSEs prefer that the shorter Alternate Form be used for refinance transactions. However, the Model Form will also be accepted provided it includes all required refinance data points.

12. How do I use the Model Form for Refinances?

The GSEs prefer that the shorter Alternate Form be used for refinance transactions. However, if the Model Form is used, provide UID 10.338 Liability Type with UID 10.350 gse:Integrated Disclosure Section Type = “DueFromBorrowerAtClosing”, along with all other required data points for each payoff or payment in the UCD file.

13. What is the UCD Critical Edits transition?

The GSEs are converting certain data edits in their UCD collection solutions from “warning” to “critical/fatal.” The multi-year rollout approach is occurring over four phases, with each phase addressing data points that closely align with given sections of the CD. The enforcement of critical/fatal edits is designed to enhance data quality and consistency for the single-family loans purchased by the GSEs.

14. How do critical edits differ from the UCD Delivery Specification (Appendix I)?

The UCD Critical Edits Matrix includes column Difference Between Specification and the Critical Edit which indicates the differences. The UCD Specification Update Impact Memo also lists the differences between the UCD Critical Edits Matrix and the UCD Delivery Specification.

15. How do we use the UCD Critical Edits Matrix?

The UCD Critical Edits Matrix lists the critical edits categorized by implementation phase. The critical edits in each phase are organized in CD Form Field ID order. The requirements for delivering each data point and the conditions when the edit will fire are provided. All additional GSE-specific data point edits are provided at the end in UCD XML order.

16. How do we prepare for the UCD Critical Edits?

The GSEs recommend preparing for the UCD Critical Edits by referring to the following resources available on the GSEs’ UCD web pages on FannieMae.com and FreddieMac.com:

• UCD Critical Edits Matrix − contains the edits and associated datapoints for all phases.
• Joint GSE UCD Phase 3 Critical Edits Feedback Message Mapping Document – aligns the feedback messages returned by each GSE’s collection solution at the data point level to further assist with Phase 3 critical edits resolution.
• Joint GSE UCD Phase 3 Critical Edits Job Aids
• Customer test environments − each GSE will provide opportunities for lenders to test their UCD XML files to resolve potential critical issues prior to the phased releases.
• Critical edits feedback message codes and text − each GSE publishes a list of feedback messages for each phase of the UCD Critical Edits for their respective UCD collection solutions.
• Appendix C: Closing Disclosure with Reference Numbers
• Appendix F: UCD Sample Use Cases
• Appendix G: UCD Sample XML Files

17. What is the implementation timing for the postponed Phase 3B edits and Phases 4 critical edits?

After the successful implementation of Phase 3B critical edits, the GSEs will turn our focus to updating the UCD Delivery Specification, as well as preparing UCD Critical Edits Phase 4 materials with the goal of publishing in 2024. The mandate for UCD Critical Edits Phase 4 remains TBD at this time.

18. Can we implement the remaining phases before the actual date?

Lenders and software partners/technology solution providers (TSPs) should consider delaying work to comply with the UCD Critical Edits Phase 4 currently published in the UCD Critical Edits Matrix. While the focus of the edits is expected to remain the same, the specific requirements may change. Updates to the requirements for the Phase 4 critical edits will be included in the UCD Delivery Specification update to be published in 2024 and the UCD Critical Edits Matrix for Phase 4. Lenders and software partners/TSPs can expect a transition period similar to that used for Phase 3.

19. Were QM data quality validations added to the critical edits?

Yes, the GSEs determined there was a need to include additional data quality updates for QM data points that were not required by the v1.5 UCD Delivery Specification. See the revised UCD Specification Update Impact Memo.

20. What and how should recording fees and amounts be included in Fee Type = “Recording Fee Total”?

The amount provided for Fee Type = “RecordingFeeTotal” should be the sum of the amounts for all recording fees expected to be paid to State or local governments that are part of the transaction. If there are recording fees in addition to Recording Fee For Mortgage and Recording Fee For Deed, those fees should be included in the Recording Fee Total as well.

21. Do we need to include Loan Discount Points, Prepaid Interest, or Lender Credits in the UCD XML file when they are not part of the loan transaction? 

• Yes. Fee Type = “LoanDiscountPoints” is required for all loans, even when discount points are not part of the transaction. Fee Actual Payment Amount is required for loan discount points and must be provided in the UCD XML file even when that value is “0.00.” Fee Total Percent is not required in the file if the Fee Actual Payment Amount is “0.00”.
• Prepaid Item Type = “PrepaidInterest” is required for all loans, even when prepaid interest is not part of the transaction. Prepaid Item Actual Payment Amount must be provided in the UCD XML file even when that value is “0.00”. 
• Integrated Disclosure Subsection Type = “LenderCredits” is required for all loans, even when lender credits are not part of the transaction. Integrated Disclosure Subsection Payment Amount is required with Lender Credits and must be provided in the UCD XML file even when that value is “0.00”.

22. In cases where a fee cannot be mapped to an exact Fee Type enumeration, is it acceptable to deliver Fee Type “Other” in conjunction with “Fee Type Other Description”?

Fee Type = “Other” and Fee Type Other Description may be used only if no matching enumeration exists. If a valid enumeration exists in the UCD for the item being represented on the CD form, then that enumeration must be used in the XML.

23. How can I reflect gifts and grants for a refinance in the UCD file on the Alternate Form?

When a refinance transaction including a gift or grant is disclosed on the Alternate Form, provide the following data points in the UCD file:

• UID 16.017 Closing Adjustment Item Type = “Gift” or “Grant”
• UID 16.016 Closing Adjustment Item Amount
• UID 16.020 Integrated Disclosure Section Type = “PayoffsAndPayments”, and
• UID 16.023 Full Name with the full name of the party providing the gift or grant.

24. I have run my loan through both Desktop Underwriter® (DU®) and Loan Product Advisor® and received an Automated Underwriting Case Identifier from both systems. Can I include the Automated Underwriting Case Identifier and Automated Underwriting System Type for both DU and Loan Product Advisor in the same UCD XML file?

Yes. You may include two instances of Automated Underwriting Case Identifier and Automated Underwriting System Type in the UCD XML file:

One with Automated Underwriting System Type = “DesktopUnderwriter” and second instance with Automated Underwriting System Type = “Other” / Automated Underwriting System Type OtherDescription = “LoanProductAdvisor”.

25. How do I determine the value that should be delivered UID 4.039 Average Prime Offer Rate Percent (APOR)?

Refer to https://ffiec.cfpb.gov/tools/rate-spread for information on how to calculate the APOR.

26. How do I identify in the UCD file fees related to a loan with a temporary buydown funded by a third party?

In the case of temporary buydowns that do not change the note rate nor impact the Cash to Close calculation, provide the following data points in the UCD file:

• Buydown Temporary Subsidy Funding Indicator = “true”
• gse:Buydown Reflected In Note Indicator = “false”
• Fee Type = “TemporaryBuydownAdministrationFee” (the total cost to the borrower for establishing the buydown fund)

Fee Type = “TemporaryBuydownPoints” should not be submitted when paid by the borrower unless a balancing amount for Seller Credits is also provided.

27. What value is expected in UID 3.038 Current Rate Set Date?

As defined in the UCD Delivery Specification per the MISMO v3.3.0 Logical Data Dictionary, Current Rate Set Date is “The date on which the interest rate for the loan was set by the lender for the final time before closing”.

28. How do I indicate that that the Secured Overnight Financing Rate (SOFR) was used as the index for an Adjustable-Rate Mortgage (ARM) Transaction?

The value “Other” should be provided in UID 11.055 Index Type and the value “SOFR” should be provided in UID 11.100 Index Type Other Description.

Note: If your business process requires delivery of ‘30DayAverageSOFR’, this value can be delivered in the UCD instead of ‘SOFR’ and will not impact the status of your UCD submission or the eligibility of the loan.

29. For construction loans, what enumeration should be provided for Loan Purpose Type?

For properties where the borrower does not own the land prior to closing of interim construction financing, the loan is classified as a Purchase transaction and “Purchase” should be provided for Loan Purpose Type. If the borrower already owns the land, the loan is classified as a refinance transaction and “Refinance” should be provided.

30. How is the subject property address provided when it does not have a street address (for example, for construction loans)?

Provide UID 1.012 Unparsed Legal Description along with UID 1.011 Postal Code.

31. How can I reflect a simultaneous second loan in the UCD file?

If the subject loan includes subordinate financing closing simultaneously, UCD Unique ID 16.015 gse:Subordinate Financing Is New Indicator = “true”. For more information regarding how to handle simultaneous second loans on the Alternate Form, refer to the CFPB’s October 1, 2014, recorded webinar entitled, “FAQs on the TILARESPA Integrated Disclosures Rule, Part 3 – Completing the Loan Estimate” and the “Index of TRID Questions Addressed During Webinars.” These can be found on the Federal Reserve System’s Consumer Compliance Outlook website.

32. What happens if my loan is selected for post-purchase review, and I have not submitted the most recent CD to the GSE collection solution?

The GSEs require that the submitted borrower closing disclosure and UCD XML file represent the most accurate agreed upon terms of the loan at the time of loan delivery to the GSEs.

If the lender determines that there is a need to reissue a closing disclosure to the borrower after loan delivery, the lender should resubmit the UCD XML file (with the associated, embedded closing disclosure PDF) updated with the latest information disclosed to the borrower.

33. The UCD contains several Ability-to-Repay (ATR) data points marked as “GSE Requirement” in Appendix I: UCD Delivery Specification. Do these data points need to be included in the UCD file?

Yes, the data points designated as “GSE Requirement” must be included in the UCD XML file as specified in the UCD Critical Edits Matrix. Ability To Repay Method Type is required for all loan types whether the loan is for a primary residence, second home or an investment property.

34. If a loan is considered to be exempt from Regulation Z’s ATR requirements, how should this be reflected in the UCD file?

The following data points and values should be included in the UCD file if the loan is classified as exempt:

• Ability To Repay Method Type = “Exempt”
• Ability To Repay Exemption Reason Type = “PropertyUsage” for ATR exempt investment properties used for business purposes or “LoanProgram” for exempt Housing Finance Agency (HFA) loans
• Refer to Fannie Mae’s Lender Letter LL-2021-11 / Freddie Mac’s Guide Bulletin 2021-19.

35. When should the data point gse:Qualified Mortgage Short Reset ARM_APR Percent be included in the UCD file?

The gse:Qualified Mortgage Short Reset ARM_APR Percent data point is required for all ARMs with a First Rate Change Months Count less than or equal to “60”. Refer to the UDC Critical Edits Matrix for the requirements for the new data point to capture the APR for ARMs.

36. Do the GSEs provide validation that the submitted XML file formation is correct?

Each GSE validates the UCD XML file formation against the MISMO v3.3.0299 Reference Model schema upon submission. In addition, each GSE provides the industry with sufficient notice regarding changes in its implementation and enforcement of any business rules. Reference the Appendix F: UCD Sample Use Cases and Appendix G: UCD Sample XML Files on the GSEs’ UCD web pages on FannieMae.com and FreddieMac.com.

37. How should I handle negative values in the UCD XML file? For example, should the Aggregate Adjustment value in the Closing Costs Details section of the Closing Disclosure be submitted as a negative value in the XML file?

In general, any value that is reflected as a negative value on the CD should be carried as a negative value in the UCD XML. Refer the Potential Sign Conflict table on page 22 of Appendix E: UCD Implementation Guide v1.4 for a presentation of the same amounts in different tables on the CD which can make it difficult to determine what sign the value should take in the XML file.

38. What is the DisplayLabelText attribute?

The DisplayLabelText attribute allows free-form text and is used for the purpose of representing the UCD supported enumerations in a more readable format, as it would be displayed on the CD. For example, a DisplayLabelText value may read as “Attorney Doc Prep Fee”, which would be the actual verbiage on the CD. A corresponding enumerated value of “DocumentPreparationFee” would also be populated in the XML along with the DisplayLabelText.

Sample XML Snippet:

Sample Form Snippet:

39. What is the purpose of the IdentifierOwnerURI attribute?

The IdentifierOwnerURI is a URL containing the web address for the organization that is responsible for (or issues) the corresponding identifier. It is important that the back slash symbol “\” not be used in the value provided. The GSEs expect lenders to use their best efforts to obtain and provide this data.

40. What resources are available to help me implement the UCD or update the UCD based on new requirements?

The GSEs have published a number of jointly developed and maintained implementation materials and artifacts on their respective Fanniemae.com and Freddiemac.com websites to assist you with your UCD implementation. It is a good practice to visit these websites frequently to ensure you are using the most up-to-date specifications and resources.

41. Does Appendix I: UCD Delivery Specification provide mapping only for data that is required on the CFPB’s CD?

No. The UCD Delivery Specification also contains a limited number of additional data points that the GSEs require beyond the fields present on the CFPB’s CD, as well as data points required to properly form the XML file. The remaining UCD data maps directly to the CD. The UCD Delivery Specification is presented in XML file order providing greater clarity regarding the data that must be delivered according to transaction type (e.g., Purchase vs. non-seller/Refinance.)